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ARTICLE · 09 MARCH 2011

Financial Services Alert - March 8, 2011

Goodwin Procter LLP
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The SEC issued proposed amendments and a proposed new rule (the "Proposed Rulemaking") that removes references to credit ratings in certain rules and forms under the Investment Company Act of 1940 (the "1940 Act"), including Rule 2a-7 governing the operations of money market funds, and establishes alternative standards of credit-worthiness.

United StatesFinance and Banking
Robert Kurucza
Robert Kurucza

Developments of Note

  • SEC Proposes Rules Removing Credit Rating References from Rule 2a-7 and Other Rules and Forms and Establishing Alternative Standards of Credit-Worthiness
  • SEC Proposes Rule on Disclosure of Incentive-Based Compensation Arrangements at Financial Institutions
  • SEC Proposes Rules on Clearing Agency Standards for Operation and Governance

Other Items of Note

  • SEC Reopens Comment Period on Ownership Limitations and Governance Requirements for Security-Based Swap Clearing Agencies, Security-Based Swap Execution Facilities, and National Securities Exchanges with Respect to Security-Based Swaps under Regulation MC
  • CFTC Proposes Conforming Amendments to Commodity Pool Operator and Commodity Trading Advisor Regulations in light of Dodd-Frank Act Changes

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